PTAB

IPR2025-00311

Shenzhen Tuozhu Technology Co Ltd v. Stratasys Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Networked Three-Dimensional Printing
  • Brief Description: The ’324 patent relates to a system for remotely accessing and controlling distributed three-dimensional (3D) printers over a data network. The system provides a user interface to a remote user that presents both a live video image of the printer's build volume captured by a camera and a two-dimensional projection of the digital 3D model being printed, from the same point of view as the camera.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mazumder and Mori - Claims 1, 3, 5-7, 9-10, and 19-22 are obvious over Mazumder in view of Mori.

  • Prior Art Relied Upon: Mazumder (Patent 6,580,959) and Mori (Application # 2010/0063615).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mazumder taught a networked 3D fabrication system that allowed a remote user to monitor and control the process in real-time via a live video stream displayed in a user interface. Mori taught a machine tool monitoring system that generated both an actual 2D image from a camera and a corresponding "virtual image" (a 2D projection) from the stored 3D model, with both views arranged from the same position and orientation. Petitioner asserted that the combination of Mazumder’s remote system with Mori’s dual-imaging user interface rendered the core limitations of independent claims 1 and 19 obvious. The combination supplied the networked printer, the camera image, and the 2D model projection within a single interface.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve the monitoring capabilities of Mazumder’s system. Providing both the actual camera view and the virtual model view would allow a user to directly compare the live fabrication process with the intended design, facilitating rapid defect detection. This dual-view also enabled continued monitoring even when the camera's view of the physical object was temporarily obscured by the printing apparatus.
    • Expectation of Success: Both references operated in the same field of remote fabrication and process monitoring. A POSITA would have reasonably expected success in integrating Mori's known user interface technique into Mazumder's known remote printing system to achieve predictable improvements in monitoring.

Ground 2: Obviousness over Kritchman, Tay, and Henke - Claims 1, 3, 5-7, 9-10, and 19-22 are obvious over Kritchman in view of Tay and Henke.

  • Prior Art Relied Upon: Kritchman (Application # 2006/0054039), Tay (a November 2001 journal article), and Henke (a July 2008 journal article).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Kritchman taught a standalone 3D printer with a controller and communications unit. Tay taught a distributed, internet-based rapid prototyping system where a remote user could monitor a build via a webcam; its user interface displayed both a virtual rendering of the model and the actual webcam feed. Henke further taught a remote lab interface that showed a virtual model and a live camera feed of the hardware simultaneously and from the same perspective. Petitioner argued that modifying Kritchman’s printer with the established networked user interface concepts of Tay and Henke rendered the challenged claims obvious.
    • Motivation to Combine: A POSITA would combine these references to add established internet-based remote control and monitoring capabilities to Kritchman's base printer. This modification directly addressed the known goal of enhancing the accessibility and utility of fabrication equipment. The combined virtual and actual views, a key feature in both Tay and Henke, would provide superior monitoring by allowing a direct, on-screen comparison between the expected progress (virtual model) and the actual result (camera feed) to identify defects.
    • Expectation of Success: Combining a hardware device (Kritchman) with a web-based remote interface (Tay, Henke) was a well-understood and common engineering paradigm for improving system utility and accessibility, leading to a high expectation of success.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges for various dependent claims by adding single references to the core Mazumder-Mori and Kritchman-Tay-Henke combinations, including Tian (for automated process monitoring), Hull (for credential-based access), Seki (for displaying a tool path), Waehner (for stop-motion capture), Lan (for a remote print server), and Anderson (for detailed status information).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. § 314(a) based on Fintiv factors would be inappropriate and that the factors favored institution. The petition was filed early in the parallel district court case, concurrently with a motion to dismiss and before an answer was filed. Petitioner highlighted the distant trial date (June 2026), the minimal investment by the court at the time of filing, and a stipulation not to pursue the IPR grounds in the district court, which would prevent overlapping issues.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 3-11, and 17-22 of the ’324 patent as unpatentable under 35 U.S.C. §103.